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-595222000Agricultural and Veterinary Chemicals (Control of Use) Regulations 2017 - Submissions Explanation:This document includes all submissions provided during public consultation on the proposed Agricultural and Veterinary Chemicals (Control of Use) Regulations 2017. The consultation period was for four weeks and closed 23 May 2017. Some submissions were provided after the end of the formal consultation period, but were considered and have been included in this anisations and individuals who requested their submission remain confidential and not be published are not included in this document. Names and personal information have been removed from the submissions.Submission Date: 15/05/2017Submission method: Engage VictoriaPostcode: 3355"Ref, Record of use, Part 2, e. Specific location.What reference point should we use, the Melbourne GPO?It seems to me that if an issue arises you would work back from there to trace the applicator, not from the applicator to the issue. If this is really a must would not a GPS lat.& long. in the paddock be enough?Part 2, h. "" if applicable the name and contact details of the person supervising the spraying ""I trust that a 'supervisor' is a licenced and experienced applicator supervising, i.e. within sight and sound, of a trainee or non-licenced person? I certainly hope it does not mean a 'contract supervisor or land manager that has no application experience or licence. e.g. a part time CMA officer who like to tell contractors how to do their job."Submission Date: 16/05/2017Submission method: Engage VictoriaPostcode: 260016 May 2017<Removed> Agvet Chemical Regulations 2017 Agriculture VictoriaDepartment of Economic Development, Jobs, Transport and Resources475 Mickleham Road Attwood VIC 3049Online submission: <Removed> ,Re: Submission to the proposed Agricultural and Veterinary Chemicals (Control of Use) Regulations 2017 - Animal Medicines Australia (AMA)On behalf of Animal Medicines Australia, thank you for the opportunity to provide our submission to the proposed Agricultural and Veterinary Chemicals (Control of Use) Regulations 2017.Animal Medicines Australia (AMA) is the peak body representing the leading animal health companies in Australia. AMA member companies are the innovators, manufacturers, formulators and registrants of a broad range of veterinary medicine products that prevent, control and cure disease across the companion animal, livestock and equine sectors.AMA and its members support the responsible, sustainable and judicious use of veterinary medicine products to support safe, healthy and productive animal production systems. Our objectives are supported by clear consistent rules that promote responsible use by veterinarians, farmers and other users.AMA does not oppose the proposed changes to the regulations. AMA and its members do not expect that the changes would represent any threat to human health, safety, animal health or animal welfare. AMA supports the simplification of processes and reductions in administrative duplication that are indicated in the proposed regulations, particularly the adoption of consistent record of use requirements for veterinary chemicals.AMA looks forward to continuing to work with the Victorian Government on measures and regulatory reforms that support Victorian farmers’ access to innovative veterinary medicine products and technologies.If you have any questions regarding our submission, or would like to discuss any issue further, please feel free to contact me.Yours Sincerely<Removed> Submission Date: 23/05/2017Submission method: Engage VictoriaPostcode: 3807The SFMCA supports the proposed changes and can see no reason for them not to be implemented.Stock Feed Manufacturers' Council of AustraliaSubmission Date: 24/05/2017Submission method: EmailPostcode: 355023/05/2017 Proposed Agricultural and Veterinary (Control of Use) Regulations 2017 Department of Economic Development, Jobs, Transport and Resources 475 Mickleham Road ATTWOOD VIC 3049 Dear Sir / Madam, Review of Proposed Agricultural and Veterinary (Control of Use) Regulations 2017 Thank you for the opportunity to provide feedback on the above proposed Regulations. Coliban Water provides drinking water and wastewater services to central and northern Victorian communities across approximately 16,500sq km. We view the protection of water supply catchments, waterways, and channels as vital for communities, as they provide Victorian townships and communities with both potable and non-potable water supplies. The minimisation of risks to the quality of raw water supplies is of paramount importance to Coliban Water, as it allows the organisation to fulfil its Duty of Care and legislative obligations under Victoria’s Safe Drinking Water Act 2003 (SDWA). This legislation provides regulatory support for the Australian Drinking Water Guidelines, and requires Water Corporations to maintain a robust, multiple barrier approach to drinking water quality, from the catchment to the customer’s tap. Additionally, Coliban Water’s interaction with Agricultural and Veterinary (AgVet) Chemicals occurs through the control and treatment of pest plants and animals on the extensive land assets we manage and maintain. These interactions include, but are not limited to, reservoirs, channel systems, wastewater reclamation plants and pump stations. The interactions have provided Coliban Water with insight and understanding into the practical application of the Regulations that apply to Agricultural and Veterinary Chemical users. Coliban Water generally supports the Proposed Agricultural and Veterinary (Control of Use) Regulations 2017, which strengthen the existing AgVet (Control of Use) Regulations in Victoria, whilst improving their usability. Beyond this general support, Coliban Water would like to make the following comments: Record Keeping Coliban Water supports the rewording of Clauses 6(1) and 6(2) for the improved clarity it provides on record keeping requirements. We would, however, request that the clause relating to ‘extent of use of the product’ (AgVet [Control of Use] Regulations 2007 Clause 5(2)(f) be retained to assist both users and regulators in calculating and determining compliance with application rates. This would strengthen the proposed regulations whilst still maintaining clarity, and could be achieved with the following rewording: (c) the rate of application of the product and one or more of the following parameters: (i) the area of land to which the product was applied; or (ii) the volume of water to which the product was applied; (iii) the volume of the stored commodity to which the product was applied; (iv) the weight of the commodity to which the product was applied. Coliban Water has concerns that the wording of Clauses 6(2)(h) and (2)(i), which commences with the phrase, ‘if appropriate’, may not provide clear guidance to AgVet Chemical users or regulators as to when these record keeping requirements should be met and could result in unintentional non-compliance. These Clauses should be reworded to clearly specify when these requirements need to be met, for example, when a restricted chemical is being applied or a commercial operator has been engaged, respectively. The benefits to Coliban Water of retaining both the extent of use provisions and improving clarity around the aforementioned clauses, relates to: demonstrating responsible use and management of agricultural chemicals, compliance with legislation, and being able to responding to any complaints regarding off-target damage or inappropriate use. Notification to Sensitive Services Coliban Water welcomes the clarification around Clause 12(2) by the inclusion of ‘…aircraft or mister…’. However, we believe that Clause 12 would benefit from further clarification by including these words in the section heading, instead, particularly as all three clauses within this section contain this wording and notifications are not applicable to other types of agricultural chemical application. This would then enable streamlining of the three clauses. We are concerned that the Regulatory Impact Statement (RIS) is largely silent on potential contamination of water supplies as a public health and/or environmental issue. The impact to water supplies from the application of AgVet chemicals poses a potentially significant risk for raw water supplies, treatment processes, and consumers and users of both potable and non-potable water supplies. The ability to reduce this risk through appropriate industry regulation on chemical application is substantial. With appropriate notification, Coliban Water may, for example, be able to change when and where water is extracted for treatment, or monitor supplies for the potential presence of AgVet chemicals, which would minimise risks to customers. Additionally, the RIS suggests that requests for notification of use of aircraft and misters in spraying is largely confined to the orchard growing area in the Goulburn Valley. The level of consultation associated with this information, however, appears to be confined to the current sensitive services listed within the Regulations; and does not include broader consultation with other stakeholders who could rightly also be considered sensitive services. Coliban Water is aware of aerial spraying in 2016 occurring on land adjoining our main channel supply to Bendigo (whilst water was being supplied), with more aerial spraying being planned in 2017. Additionally, the orchard growing area of Harcourt, in close proximity to our Barkers Creek Reservoir (irrigation and domestic and stock water supplies), is also likely to be a high user of mister application techniques. With no notifications of when aerial or mister chemical application is occurring, Coliban Water is limited in the approaches that it can implement to mitigating risks to customers. Coliban Water considers it appropriate that in the case of aircraft and mister application of AgVet chemicals, that Water Corporations be considered an appropriate Sensitive Service. Hence, we respectfully request this be reflected in the Clauses under section 12, through the addition of notifications to Water Corporations. Coliban Water does not believe this would add significantly to the costs associated with meeting this regulation, either for the customer or the industry, but it would add significant potential health benefits to customers and the wider community. We support DEDJTR’s retention of the more prescriptive approach to spray drift management for aerial spraying for the reasons outlined in the RIS benefits and costs assessment and do not believe it would be appropriate to move to performance based regulation in this circumstance. Prohibition on Possession of Unregistered AgVet Chemicals Coliban Water welcomes the inclusion of s14 that is related to it being an offence to possess certain (six) agricultural chemical products based on chemicals considered likely to pose significant risks. Whilst this is a strengthening of the current regulations, Coliban Water believes that it would be more appropriate, and would support the adoption of, a general prohibition on the possession of any unregistered AgVet Chemicals. Coliban Water believes this would provide greater public and environmental benefits, and be a deterrent to users retaining or using chemical products (either deliberately or inadvertently) past their ‘used by’ dates, whilst also discouraging the exchange of unregistered products between AgVet Chemical users. Whilst Coliban Water recognises that this may increase administrative and compliance costs associated with the Regulations, we believe the public and environmental health benefits are likely to far outweigh any associated costs. It may also be possible to offset some of the cost, by including a clause that provides an ‘amnesty period’ after the expiry date (i.e. 1 year) of a chemical to enable users to dispose of unregistered chemicals through an appropriate facility or service. Please do not hesitate to contact <Removed> should you have any queries or would like to discuss in more detail Coliban Water’s submission.Yours sincerely,<Removed> Submission Date: 23/05/2017Submission method: Engage VictoriaPostcode: 6111Please review the attached PDF file on 1080 poison. 1080 is deemed by the RSPCA as an inhumane toxin. Currently, registrations of toxins does not take into account the inhumane nature of death. It should. 1080 bas also been identified as a chemical of concern by COAG as a potential weapon for use by terrorist organisations. Currently it is far too easy to access. Dingo AssociationSubmission Date: 23/05/2017Submission method: Engage VictoriaPostcode: 3093DCN opposes the use of 1080. It causes a very painful death, which may last up to 18 hours. In a modern society where humane treatment of animals is an accepted part of life this is unacceptable.Third world countries have banned the use of 1080, it is time Australia followed suit. We are just one of two countries that continues to use this barbaric chemical. The farmers who are advocating and using 1080 are the same farmers who are distressed at the site of stock injured by dingo/wild dog attacks. There are alternatives which farmers must be strongly encouraged to implement. Those already using maremmas to protect livestock state, there stock produce better meat and wool as they are more relaxed, their lambing/calving rates are greatly improved, the management of maremmas is time effective (takes less time than lethal control) and farmers report improved mental health as they are not listening for dingoes/wild dogs at night.It is time to cease the use of 1080.Dingo Care NetworkSubmission Date: 23/05/2017Submission method: Engage VictoriaPostcode: 25391080 should be banned!! It kills everything. And kills its victims slowly and painful.Submission Date: 23/05/2017Submission method: Engage VictoriaPostcode: 6030This country has to follow the lead of the rest of the world and ban 1080 all together.This toxin kills indiscriminately and is disgusting cruel in the manner it kills.Our native Dingo populations are being systematically wiped out right across the nation due to this poison and other natives like Wedgetail Eagles and Quolls has been dramatically affected.This has to stop.Submission Date: 23/05/2017Submission method: Engage VictoriaPostcode: 3337I believe we should Ban all use of the poison of 1080, trapping and aerial baiting as these forms of control on introduced species is just cruel and inhumane, also these forms don't just killed the targeted species, it affects our native animals and affects our environment.Submission Date: 23/05/2017Submission method: Engage VictoriaPostcode: 5070All use of 1080 and any similar use of baits and poisons is ecologically treacherous and in the long-term catastrophic. We must help reintroduce healthy Dingo packs into every territory especially when overrun with feral animals destroying more of what is left of the multitude of fragile ecosystems. Submission Date: 23/05/2017Submission method: Engage VictoriaPostcode: 3178I totally and absolutely disagree with the use of any poisons or baits to cull our dingo population. I think this is barbaric an will absolutely NOT achieve what is claimed. It will disrupt the whole eco -balance which is under enough pressure already. Consider the wolf recovery program implemented in the USA which has proven the value of wolves on their environment. Likewise dingos are critical to our eco culture.Poisons are NOT the answer.Submission Date: 23/05/2017Submission method: Engage VictoriaPostcode: 3584by taking out the top predator in Australia the whole ecosystem is out of balance, have a look at the large properties that are now letting the dingo roam free and can run more stock as well as watching the native flora and fauna grow. it is so easy, just stop killing the dingo.Submission Date: 23/05/2017Submission method: Engage VictoriaPostcode: 6308Please stop the use of 1080. It is an abhorrent poison which endangers the life of all animals that come into contact with it directly or through secondary poisoning. It is inhumane for any animal to take up to 20hrs to die an agonising death. The answer to controlling pest species in Australia- cats, rabbits, wild dogs (not Dingoes!) pigs and foxes is simple and free. Dingoes. Protect dingoes and leave them to re-establish stable family groups and within a few years the feral problem will be under control, and our endangered natives will have a greater chance of survival.Farmers can use guardian animals to prevent any predation on their sheep. It is time they took responsibility and stopped looking to the government to protect their assets. Pure dingoes are endangered. All government policy currently perpetuates mistakes of the past. Remember the Thylacine? Policies demanding poisoning, trapping, bounties. Eradicated.Submission Date: 23/05/2017Submission method: Engage VictoriaPostcode: 4022I am currently living in England, but I am Australian through and through... and I vote in elections in Australia.The use of 1080 baits should be banned in Australia.... completely. Killing animals through this inhumane manner is inexcusable.Doesn't anybody there bother studying biology? Have you ever heard of the food chain? Dingoes are part of the Australian natural food chain. This is why there is kangaroo overpopulation. A better idea would be to allow the natural biological balance to be restored in Australia.Submission Date: 23/05/2017Submission method: Engage VictoriaPostcode: 3316I cannot believe Australia still uses this chemical...and when you basically think about dropping poisoned meat all over the land even a child can advise it is not a good idea....stop the madness!Submission Date: 23/05/2017Submission method: Engage VictoriaPostcode: 3960The Australian Dingo is currently endangered and threatened at the hands of Government wild dog control. There are no current conservation strategies that will reduce the rate of extinction. They cannot keep baiting wild dogs without eradicating the Dingo, whether it be by aerial baiting, ejector traps, 1080 or Papp. A different approach is necessary to end the persecution.Submission Date: 24/05/2017Submission method: Engage VictoriaPostcode: xxxxYou know the hazards, Dangers and Cruelty but you still Need to Ask for Opinions !!?? SERIOUSLY !!! Health/Enviromental HAZARD !! Animal CRUELTY! ! BARBARIC, INHUMANE,TOXIC,GUTLESS,LOWLIFE ACT ! 1080 WHAT THE FUCK IS AUSTRALIA DOING STILL USING THIS BARBARIC SHIT !!!!!!!!!!!!!!!!!Submission Date: 24/05/2017Submission method: Engage VictoriaPostcode: 43001080 and other lethal baits needs to be banned Australia wide.Australia needs to totally reassess their relationship with Dingoes, and that means NO lethal control. The only people doing well from the sale of 1080 are those peddling it.The dollars paid to the poisons companies would be better used to pay farmers directly in support of better livestock fencing, guardian animals and fox lights etc.Submission Date: 24/05/2017Submission method: Engage VictoriaPostcode: 3782To whom it may concern,I am against 1080 as it is a slow painful death and it is banned in many countries.It is not able to be targeted at specific breeds and in baiting for foxes there are many secondary poisoning of other native animals that we are supposed to be protecting. I am concerned for public safety when the poisoned animals die in our catchment areas and in livestock drinking areas. Regards <Removed> Submission Date: 24/05/2017Submission method: Engage VictoriaPostcode: 39571080 is a horrifically cruel poison that should be phased out in favour of more humane poisons such as PAPP. The use of 1080 cannot be ethically justified.Submission Date: 24/05/2017Submission method: Engage VictoriaPostcode: 3806My concern is outlined in the attached document and is in regard to Victoria's Department of Environment, Land, Water and Planning (DELWP)'s unlawful and unwarranted mismanagement in regard to current uses of 1080 and that needs to be considered in regard to any changes to regulations.This toxic substance should be banned in Australia. Its dangerous for our environment and it has the potential to be dangerous to humans. Its a cruel substance which has been outlawed in nearly every country, except Australia and NZ. It is time for us to outlaw it too!Submission Date: 24/05/2017Submission method: Engage VictoriaPostcode: 2470Don't need much thought dingoes, beautiful, smart, and worth more to the land than 1080 baits will ever equal too. 1080 doesn't just kill dingoes and wild dogs. Our native animals and the occasional pet. Yes than cause problems with live stock, but there are better alternatives than 1080. We can teach and provided farms with info on dingo friendly farming. Dingoes are not aggressive creatures, they are timid and shy and curious but that isn't worth there lives.Submission Date: 23/05/2017Submission method: Engage VictoriaPostcode: 31991080 was used extensively as way to eridicate vermon such as rabbits by way of baiting these animals with contaminated food. The subsequent result was that the infected animals where consumed by upper food chain. This means predators such as native eagles, domestic and wild dogs, foxes and dingoes were also poisoned. Poison left laying on the ground also killed livestock affecting farmers livelihoods.1080 needs to be placed on the banned chemical list because of the damage it causes to the wildlife, wildlife foodchain, and farmers. ................
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